Code of Conduct

1. Honesty and Fairness

The Research Analyst shall act with honesty and fairness in conducting his/her activities and shall not engage in any act, omission or course of conduct that amounts to manipulation or deception of investors.

2. Diligence and Competence

The Research Analyst shall:

• Act with competence, care, and diligence.
• Maintain and improve professional knowledge, skills, and competence.
• Ensure that research reports are based on thorough analysis and research.
• Not provide research reports based on rumor, hearsay, or unverified information.

3. Independence and Objectivity

• All research shall be conducted independently and objectively.
• The Research Analyst shall not compromise independence for commercial considerations.
• Research reports shall not be influenced by the subject company or third parties.
• Conflicts of interest shall be disclosed promptly and fully.

4. Disclosure of Conflicts of Interest

• Disclose any financial interest in securities recommended in research reports.
• Disclose any compensation received from subject companies.
• Disclose any position held in securities of subject companies.
• Ensure disclosures are clear, prominent, and not misleading.

5. Client Interests First

• Place the interests of investors above personal interests in all research activities.
• Provide balanced and unbiased research views.
• Ensure research is in compliance with SEBI regulations at all times.

6. Compliance with Regulations

• Comply with all applicable laws, regulations, and SEBI guidelines.
• Maintain required records and registers as per SEBI regulations.
• Submit timely returns, reports, and disclosures to SEBI and exchanges.
• Co-operate fully with SEBI and exchange inspections.

7. Prohibition on Insider Trading

The Research Analyst shall not engage in or facilitate insider trading. All research shall be based on publicly available information. The Research Analyst shall maintain appropriate information barriers to prevent misuse of non-public information.

8. Fair Dealing

The Research Analyst shall deal fairly with all investors and shall not discriminate between investors based on their size, relationship, or any other factor in providing access to research reports.

9. Prohibition on Churning

The Research Analyst shall not issue research reports with the intent of inducing frequent trading activity that is not in the best interest of investors.

10. Record Keeping

• Maintain records of all research reports for a minimum period of 5 years.
• Maintain records of client agreements and communications.
• Maintain records of complaints and their resolution.

11. Prohibition on Guarantees

The Research Analyst shall not make any promise or guarantee of returns or profits from investments based on research reports. All research is provided on a best-effort basis.

Last Updated: 26th April 2026